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DROPLETS

AmLaw 100 Legal Intelligence — Distilled
Sunday, September 6, 20264 featured14 also noted14 firms4 practice areasgrade 3–5
Quick Scan — Why It Matters
Hogan LovellsCorporate / M&A+ Expand
Analysis: PE Sponsors Delaying Exits by Choice

A new analysis argues the slow pace of private fund exits stems not from a 'challenging environment' but from a discretionary choice by sponsors holding out for higher valuations to meet anchored IRR goals.

A new analysis challenges the widely held belief that a "challenging exit environment" is suppressing private fund M&A and IPO activity. The commentary argues that market indicators, from debt capital access to equity availability, show an exceptionally accommodative environment for financing transactions. Instead of external constraints, the lull in exits is attributed to a deliberate "timing preference" by fund sponsors.

This perspective is critical for sophisticated counsel and their clients because it reframes the deal slowdown as a discretionary choice, not a market necessity. Sponsors are reportedly holding onto assets because their anchored internal rate of return (IRR) expectations are difficult to achieve in the current interest-rate environment, creating a valuation disconnect with potential buyers. This insight helps clarify borrower motivations for lenders and highlights the strategic gamble sponsors are taking. The key development to watch is whether sponsors will reset their return targets or if rising asset values will eventually bridge the valuation gap.

Read the full dispatch →
Alston & BirdRegulatory / Government+ Expand
CR Delays Rule Tightening Federal Grant Award Oversight

A continuing resolution signed into law temporarily blocks the OMB's proposed rule that would make its grant guidance binding on all agencies and require political appointee review of discretionary awards.

President Trump signed the Continuing Appropriations and Extensions Act, 2027, a continuing resolution (CR) funding the U.S. government through December 11, 2026. A key provision within the CR blocks the Office of Management and Budget (OMB) from finalizing or implementing its May 2026 proposed rule on federal financial assistance. The proposed rule represents a significant shift in the administration of federal grants. It would transform the existing framework from nonbinding guidance into formally binding regulations applicable to all agencies. Crucially, the proposal would also require that discretionary awards receive a pre-issuance review from senior political appointees to ensure compliance with administration priorities and applicable law. This change could introduce a substantial new layer of political oversight into the grant-making process, affecting the many clients—from research institutions to non-profits—that depend on federal funding. The legislative block offers these stakeholders a temporary reprieve. The prohibition is tied to the CR's expiration date. Counsel for g

Read the full dispatch →
Morgan, Lewis & BockiusFDA / Life Sciences Regulatory+ Expand
Women's Health Innovation Attracts Investment and Scrutiny

Investors and strategic partners are increasingly targeting the women's health sector, creating new opportunities but also demanding more rigorous clinical, regulatory, and transactional strategies.

The women's health sector is evolving from an underinvested niche into a commercially viable ecosystem, attracting heightened interest from investors, strategic partners, and pharmaceutical companies. This guide advises that stakeholders are now demanding more sophisticated and rigorous approaches to innovation, with a focus on closing historical data gaps and improving clinical evidence.

Sophisticated counsel should note that regulators and acquirers are increasing scrutiny on clinical trial diversity, the use of patient-centered endpoints, and the validity of data used for AI-enabled diagnostics. Companies developing drugs, devices, or digital health tools must navigate complex regulatory, privacy, and reimbursement landscapes to de-risk assets for financing or acquisition. For investors, due diligence must now more carefully assess the quality of women-specific clinical data, regulatory strategy, and data rights. Proactive legal strategy—addressing IP, contracts, and regulatory engagement early—is presented as critical for any company seeking to capitalize on the sector's growth.

Read the full dispatch →
Cozen O'ConnorSecurities / Capital Markets+ Expand
SEC Ends No-Action Letters for Rule 14a-8 Shareholder Proposal Exclusions

The SEC's Division of Corporation Finance will no longer respond to any Rule 14a-8 no-action requests, leaving companies without an authoritative backstop for excluding shareholder proposals from proxy materials.

The SEC's Division of Corporation Finance announced it will no longer respond to any no-action requests under Exchange Act Rule 14a-8, effective immediately. This permanently expands a 2025 policy that had already sharply curtailed such responses. Companies have historically relied on these letters to gain the Division's informal agreement that a shareholder proposal could be legally excluded from proxy materials. Without this authoritative backstop, companies and their counsel bear the full risk of exclusion decisions, likely leading to more litigation from shareholder proponents challenging those determinations. Companies must still notify the SEC and proponents of any decision to exclude a proposal 80 days before filing definitive proxy materials, but counsel should now draft these notices for an audience of the proponent and, potentially, a court.

Read the full dispatch →
DIG DEEPER
MOST CONSEQUENTIALAnalysis: PE Sponsors Delaying Exits by Choice

A new analysis argues the slow pace of private fund exits stems not from a 'challenging environment' but from a discretionary choice by sponsors holding out for higher valuations to meet anchored IRR goals.

A new analysis challenges the widely held belief that a "challenging exit environment" is suppressing private fund M&A and IPO activity. The commentary argues that market indicators, from debt capital access to equity availability, show an exceptionally accommodative environment for financing transactions. Instead of external constraints, the lull in exits is attributed to a deliberate "timing preference" by fund sponsors.

This perspective is critical for sophisticated counsel and their clients because it reframes the deal slowdown as a discretionary choice, not a market necessity. Sponsors are reportedly holding onto assets because their anchored internal rate of return (IRR) expectations are difficult to achieve in the current interest-rate environment, creating a valuation disconnect with potential buyers. This insight helps clarify borrower motivations for lenders and highlights the strategic gamble sponsors are taking. The key development to watch is whether sponsors will reset their return targets or if rising asset values will eventually bridge the valuation gap.

Hogan LovellsCorporate / M&A
private-equitymergers-acquisitionsexit-strategiesinterest-ratescapital-marketsirrdeal-flow
AR
Today's Curator
Arthur Rodrigues. Corporate Counsel & Corporate Secretary at Teachable, Inc. Founder of Cicero Intelligent Minds. Former BigLaw (O'Melveny, Weil, Hughes Hubbard). JD/LLM Michigan Law.
Full Analysis — The Details
01 — CORPORATE / M&A1
Hogan Lovells+ Expand
Analysis: PE Sponsors Delaying Exits by Choice

A new analysis argues the slow pace of private fund exits stems not from a 'challenging environment' but from a discretionary choice by sponsors holding out for higher valuations to meet anchored IRR goals.

A new analysis challenges the widely held belief that a "challenging exit environment" is suppressing private fund M&A and IPO activity. The commentary argues that market indicators, from debt capital access to equity availability, show an exceptionally accommodative environment for financing transactions. Instead of external constraints, the lull in exits is attributed to a deliberate "timing preference" by fund sponsors.

This perspective is critical for sophisticated counsel and their clients because it reframes the deal slowdown as a discretionary choice, not a market necessity. Sponsors are reportedly holding onto assets because their anchored internal rate of return (IRR) expectations are difficult to achieve in the current interest-rate environment, creating a valuation disconnect with potential buyers. This insight helps clarify borrower motivations for lenders and highlights the strategic gamble sponsors are taking. The key development to watch is whether sponsors will reset their return targets or if rising asset values will eventually bridge the valuation gap.

private-equitymergers-acquisitionsexit-strategiesinterest-ratescapital-marketsirrdeal-flow
Read the full dispatch →
02 — FDA / LIFE SCIENCES REGULATORY1
Morgan, Lewis & Bockius+ Expand
Women's Health Innovation Attracts Investment and Scrutiny

Investors and strategic partners are increasingly targeting the women's health sector, creating new opportunities but also demanding more rigorous clinical, regulatory, and transactional strategies.

The women's health sector is evolving from an underinvested niche into a commercially viable ecosystem, attracting heightened interest from investors, strategic partners, and pharmaceutical companies. This guide advises that stakeholders are now demanding more sophisticated and rigorous approaches to innovation, with a focus on closing historical data gaps and improving clinical evidence.

Sophisticated counsel should note that regulators and acquirers are increasing scrutiny on clinical trial diversity, the use of patient-centered endpoints, and the validity of data used for AI-enabled diagnostics. Companies developing drugs, devices, or digital health tools must navigate complex regulatory, privacy, and reimbursement landscapes to de-risk assets for financing or acquisition. For investors, due diligence must now more carefully assess the quality of women-specific clinical data, regulatory strategy, and data rights. Proactive legal strategy—addressing IP, contracts, and regulatory engagement early—is presented as critical for any company seeking to capitalize on the sector's growth.

womens-healthlife-sciencesfda-regulatoryclinical-trialsma-due-diligenceventure-capitaldigital-healthfemtech
Read the full dispatch →
03 — REGULATORY / GOVERNMENT1
Alston & Bird+ Expand
CR Delays Rule Tightening Federal Grant Award Oversight

A continuing resolution signed into law temporarily blocks the OMB's proposed rule that would make its grant guidance binding on all agencies and require political appointee review of discretionary awards.

President Trump signed the Continuing Appropriations and Extensions Act, 2027, a continuing resolution (CR) funding the U.S. government through December 11, 2026. A key provision within the CR blocks the Office of Management and Budget (OMB) from finalizing or implementing its May 2026 proposed rule on federal financial assistance. The proposed rule represents a significant shift in the administration of federal grants. It would transform the existing framework from nonbinding guidance into formally binding regulations applicable to all agencies. Crucially, the proposal would also require that discretionary awards receive a pre-issuance review from senior political appointees to ensure compliance with administration priorities and applicable law. This change could introduce a substantial new layer of political oversight into the grant-making process, affecting the many clients—from research institutions to non-profits—that depend on federal funding. The legislative block offers these stakeholders a temporary reprieve. The prohibition is tied to the CR's expiration date. Counsel for g

ombfederal-grantscontinuing-resolutionadministrative-lawgovernment-fundingregulatory-affairs
Read the full dispatch →
04 — SECURITIES / CAPITAL MARKETS1
Cozen O'Connor+ Expand
SEC Ends No-Action Letters for Rule 14a-8 Shareholder Proposal Exclusions

The SEC's Division of Corporation Finance will no longer respond to any Rule 14a-8 no-action requests, leaving companies without an authoritative backstop for excluding shareholder proposals from proxy materials.

The SEC's Division of Corporation Finance announced it will no longer respond to any no-action requests under Exchange Act Rule 14a-8, effective immediately. This permanently expands a 2025 policy that had already sharply curtailed such responses. Companies have historically relied on these letters to gain the Division's informal agreement that a shareholder proposal could be legally excluded from proxy materials. Without this authoritative backstop, companies and their counsel bear the full risk of exclusion decisions, likely leading to more litigation from shareholder proponents challenging those determinations. Companies must still notify the SEC and proponents of any decision to exclude a proposal 80 days before filing definitive proxy materials, but counsel should now draft these notices for an audience of the proponent and, potentially, a court.

sec-no-action-lettersrule-14a-8shareholder-proposalsproxy-rulescorporate-governancesecurities-regulation
Read the full dispatch →
Also noted

Grade 3 — worth a glance, not the full analysis.

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